Johnson v. Robison
Citation: 415 U.S. 361 (1974) Court: Supreme Court of the United States
Facts
William Robison was a conscientious objector who performed alternative civilian service rather than military service during the Vietnam era. When he was denied veterans’ educational benefits under the Veterans’ Readjustment Benefits Act — which limited benefits to those who performed active military duty — he sued the Administrator of Veterans’ Affairs. The statute contained a provision expressly precluding judicial review of veterans’ benefit decisions. Robison argued the statute violated the First and Fifth Amendments.
Issue
Whether a statutory provision precluding judicial review of veterans’ benefit determinations also bars constitutional challenges to the benefit statute itself.
Holding
The Supreme Court held that the preclusion provision applied only to interpretations of the benefits statute; it did not bar a federal court from adjudicating a constitutional challenge to the statute’s validity.
Rule / Doctrine
APA §701(a)(1) express preclusion of judicial review is construed narrowly. A statute that forecloses review of agency benefit determinations does not, without clear congressional statement, foreclose review of constitutional challenges to the statute itself. Courts distinguish between review of agency action under a statute and review of the constitutionality of the statute.
Significance
Johnson v. Robison is a foundational case on the limits of express preclusion clauses under §701(a)(1). It establishes that even sweeping “no review” language does not eliminate Article III jurisdiction to hear constitutional attacks on the underlying statute. The case is regularly paired with Webster v. Doe (constitutional claims surviving statutory preclusion) and contrasted with Block v. Community Nutrition Institute (implied preclusion). On the merits, the Court found no constitutional violation, upholding the benefit distinction between conscientious objectors and veterans.